Ethics Policy

PAPİLON ETHICS POLICY

I. PURPOSE
At Papilon, our primary aim in establishing the Ethics Policy is to create a shared corporate culture, foster a harmonious work environment, and act as a socially responsible company. In this regard, our goals are to enhance the company while safeguarding its reputation, comply with legal requirements, act in line with stakeholders’ expectations, protect and strengthen the company’s position against competitors, mitigate the potential impacts of any misuse or crisis, and ensure that the company adapts to changes.

II. SCOPE AND RESPONSIBILITIES
This Policy applies to Papilon Defense Technology and Trade Incorporated Company, established in 2012, and all its employees. It is overseen by the Board of Directors, implemented through the Human Resources Department and Ethics Representatives. The Policy was created to compile and share our corporate ethical codes and values within the organization, aiming to provide a healthier work environment for employees and to develop the company with integrity. We believe that ethics, as a living concept, must sustainably contribute to our corporate culture.

The ethical code, by common definition, is a set of written rules established to define universal truths in business life, guide actions based on these truths, and direct employee behavior. Every member of the Papilon family is expected to fully adhere to the Papilon Ethical Codes and comply with each ethical rule outlined in this Policy. Members of the Board of Directors follow the behavioral rules defined in the Ethics Policy.

This Policy informs employees about the requirements for conducting our shared business life in the most ethical manner and explains how to achieve this goal. For this reason, the Papilon Ethics Policy is publicly available on our corporate website, accessible to everyone. No employee is granted special privileges under this Policy; all employees are evaluated equally. Employees who witness unethical actions but fail to report them are considered to have violated ethical rules. Ethics Representatives report ethical violations in writing to the Board of Directors.

1. CORE ETHICAL PRINCIPLES
One of Papilon’s fundamental principles is to develop the company in a way that meets the expectations of all stakeholders and society. A member of the Papilon family is aware that the most fundamental resource is ‘people.’ They act with care and moderation toward all living beings due to their value and utility. They never belittle any person, their rights, or their ideas; they value individuals, their rights, and their ideas. They establish relationships based on open communication, acting with goodwill, understanding, and respect. They strive to embrace a sense of corporate belonging. They encourage diverse ideas, decisions, teamwork, collective reasoning, and flexible thinking/behavior. These principles, expected to be applied without compromise, should be regarded by all employees as the foundational criteria for their workplace responsibilities, ensuring the sustainability of the corporate culture and the Papilon brand.

2. CODE OF CONDUCT
At Papilon, all employees act with awareness of their responsibilities. They manage their stress and emotions, using them as tools for motivation and enhancing teamwork effectiveness. They take care not to exhibit behaviors that would make others feel unsafe.

They adopt a proactive approach to managing differences and conflicts, resolving conflicts constructively. While striving to achieve goals, they take responsibility for all activities. They are aware that this attitude, known as accountability, must be consistently demonstrated without deviation.

They strive to prevent unethical behavior and issue necessary warnings. They do not engage in actions that hinder colleagues from performing their duties or disrupt workplace harmony. They avoid statements about third parties that could disrupt workplace harmony or cooperation. Through honest and consistent behavior, they strengthen trust with colleagues. When meeting with stakeholders, they represent Papilon in the best possible manner, paying attention to their behavior and attitude. They act sensitively in the use of shared company spaces. They perform their duties within the framework of fundamental moral and human values.

3. PREVENTING CONFLICTS OF INTEREST
At Papilon, misusing status, individual power (e.g., title, physical attributes, age), or collective power (e.g., strength in numbers) for personal gain is considered a violation of rules. Employees may not enter into any business relationships that unfairly benefit themselves, their relatives, or third parties by leveraging their title or authority. If a relative holds a stake or financial interest in a company with which Papilon has a commercial relationship, the employee must inform their manager. Employees do not use or allow the use of Papilon’s assets for their own benefit or that of anyone inside or outside the company. All employees prioritize Papilon’s interests over their own. They also enable differences to be turned into advantages while preventing them from creating superiority.

4. SOCIAL RESPONSIBILITY
All Papilon employees are supported by the company to voluntarily participate in social activities with a sense of social responsibility. Employees frequently engage in helping, taking responsibility, and taking ownership. They learn and teach. They strive for their own well-being and that of their colleagues. They exhibit open, honest, and consistent cooperation with stakeholders.

5. CONFIDENTIALITY
All Papilon employees understand the importance of internal information and ensure its confidentiality regardless of location. They do not use internal information for personal or third-party gain and take care to protect its confidentiality. While safeguarding the company’s confidentiality and integrity, they treat all tangible and intangible assets as if they were their own and protect them. Unless required by official authorities or laws, they do not share confidential information with third parties. They do not disclose information about internal processes, intellectual property, knowledge, or inventions acquired through their duties. They recognize that salary information is personal, do not share it with others, and do not attempt to learn others’ salaries. They do not share internal information in public places inside or outside the company. They do not disclose confidential information or documents from previous employers to Papilon or colleagues, nor do they request such information from others.

6. PREVENTING DISCRIMINATION AND HARASSMENT
Papilon employees view every individual as equal, regardless of religion, language, race, gender, political or other opinions, or national and social origin. They treat everyone equally and with respect, regardless of age, language, race, ethnicity, health status, gender, marital status, religion, cultural background, political views, or philosophical beliefs. They recognize diversity as a strength. They do not tolerate actions or behaviors that violate this principle and warn those engaging in discriminatory treatment. In recruitment processes, they do not discriminate based on gender, age, religion, language, race, ethnicity, or national origin. In hiring and promotion, they consider only job-relevant qualifications and skills, ensuring equal opportunity and impartiality.

7. PROTECTION OF ANIMALS AND THE ENVIRONMENT
Papilon acts with environmental awareness, warns those who do not, and works to increase this awareness. No employee engages in behaviors that threaten the environment. Employees avoid any actions that would make any living being feel unsafe. They work to develop environmentally friendly technologies.

8. OCCUPATIONAL HEALTH AND SAFETY
Papilon strives to provide a safe work environment and fulfill its environmental responsibilities. Employees comply with occupational health and safety measures in the workplace. They avoid behaviors that would make others feel unsafe.

9. INVESTOR RELATIONS
The methods for public disclosures by authorized persons are outlined in Papilon’s Disclosure Policy, and actions are taken in accordance with these regulations. The Papilon Investor Relations Unit ensures compliance with Capital Markets Legislation obligations.

10. COMPLIANCE WITH LAWS AND COMPANY ETHICAL CODES
All Papilon employees have responsibilities regarding compliance with laws and company ethical codes. They ensure that all records are maintained and archived accurately within legal timeframes. They are obligated to report any situations they observe or suspect to be contrary to applicable laws, regulations, or Papilon policies. They do not seek unfair gains from individuals or organizations for any purpose. Unless explicitly authorized, they do not engage in actions, statements, or correspondence that would place the company under liability. They always comply with laws.

11. FIGHTING BRIBERY AND CORRUPTION
Papilon has a zero-tolerance policy toward bribery and corruption. This rule applies to all Papilon employees, Board Members, shareholders, and stakeholders in commercial and social relations with Papilon. Bribery and corruption are strictly prohibited in all cases. This rule applies equally in all countries where Papilon operates or is represented. Violating these regulations can harm the company’s reputation and lead to serious legal and criminal consequences. At Papilon, we believe in the importance of transparency and accountability and take necessary measures to prevent all forms of bribery and corruption.

If any Papilon employee or stakeholder witnesses an action related to bribery or corruption, they must immediately report it to the Ethics Representatives. In cases where complaints are reported or Ethics Representatives directly detect bribery or corruption:

a. Upon detection of any action or attempt related to bribery or corruption, immediate notifications are made to legal authorities without delay.
b. If an employee is found to be involved in bribery or corruption, or upon a complaint to the Ethics Representatives, the employee’s written defense is obtained, and necessary actions are taken immediately. Considering the principle that termination is a last resort, sanctions such as warnings, reprimands, or salary deductions may be applied.

12. GIFTS AND DISCOUNTS
Papilon employees act with discretion regarding the acceptance of gifts and discounts; they do not accept benefits such as gifts exceeding a total annual value of 500 TL. If gifts are received from authorities where refusal would be inappropriate and are within courtesy limits, they are reported to the Human Resources Department within 2 days. Reported gifts are kept under Papilon’s custody. With senior management’s knowledge, employees may offer modest promotional materials as gifts during visits to contribute to Papilon’s promotion. They may accept invitations related to business meetings or collaborative activities (e.g., lunch during meeting hours, organized dinners, or cocktails afterward).

Gifts or benefits implicitly or explicitly tied to a quid pro quo, giving or receiving bribes or commissions, or proposing such are strictly prohibited. Employees must not accept money, loans, or expenses (e.g., events, accommodation, travel) from business-related individuals or entities under any circumstances. In international business trips requiring mutual gift exchanges, such gifts are given or accepted only on behalf of the company with senior management’s approval.

13. POLITICAL ACTIVITIES
Papilon does not engage in activities supporting political parties, politicians, or candidates. It does not make donations to such entities. Papilon employees respect everyone’s political views. They do not participate in propaganda or similar activities. While conducting its operations, Papilon maintains an equal distance from civil society organizations, political parties, and all public institutions without expecting benefits and carries out its activities with this sense of responsibility. Employees do not run for office in elections without resigning from Papilon. They do not use Papilon resources for political activities.

14. REPORTING INAPPROPRIATE BEHAVIOR
All suspicions regarding violations of laws or business ethics principles must be reported to the Ethics Representatives as soon as possible.

The Ethics Representatives consist of:

• Chairperson – Papilon Board Member
• Member – Papilon Legal Advisor
• Member – Papilon Human Resources Manager

If individuals prefer not to report inappropriate behavior or suspicions in person, they can use the ethics hotline without concern. Complaints or suspicions can be reported, or contact can be made, via the email address etik@papilon.com.tr or fax number 0 (312) 231 20 28. Additionally, the Human Resources Manager can be reached at 0 (312) 231 20 26.

The purpose of the ethics hotline is to provide clear information to individuals when there is uncertainty about the Papilon Ethics Policy and to enable the reporting of suspected ethical violations without hesitation. Any complaint or suspicion is evaluated by the Ethics Representatives as soon as possible.